Now viewing articles in the category Compliance.

  • Top 10 Differences Between the 2003 and 2016 Massachusetts MS4 Permit

    July 29th, 2016 by Eileen Pannetier


    As you may be aware, there are many differences between than 2003 and 2016 MS4 permit. CEI has been analyzing the changes, and to help simplify a complicated permit, we’ve boiled down the most significant changes to 10. Here they are:

    1. The 2016 permit has very specific public outreach and participation requirements, divided by audience and with definitive requirements for distribution. This may be something you will can do using materials created by your regional planning agency, MassDEP or EPA.

    2. The requirements for regulatory changes include incorporation of specific design requirements for new development and redevelopment largely tied to the Massachusetts Stormwater Handbook. Previously, regulations were required but did not specify design criteria and many communities did not implement any subdivision or site plan requirements.

    3. Stormwater Pollution Prevention Plans (SWPPPs) will be required at all municipal maintenance garages, public works yards, transfer stations, and other waste handling facilities, previously only required for construction sites and certain industrial facilities regulated by different permit programs.

    4. Municipalities will be required to identify five municipal-owned properties that could potentially be modified or retrofitted with structural best management practices (BMPs) and maintain a minimum of five sites in their inventory for future improvements.

    5. Street sweeping is required once per year throughout the regulated area, and twice per year in areas that discharge to nutrient impaired water bodies. Previously street sweeping was considered a best management practice but was not required.

    6. Catch basins must be cleaned when they are less than 50% full, which suggest that they will need to be inspected prior to that.

    7. Mapping of the entire regulated MS4 system must be performed, including outfalls with contributing catchment areas, interconnections, and open channel conveyances by Year 2, and pipes, manholes, catch basins, and treatment structures by Year 10. Previously, only outfalls had to be mapped.

    8. Catchment investigations must be performed and include dry weather screening of all key junction manholes/structures regardless of whether dry weather flow is observed at the outlet. Any dry weather flows observed must be sampled and analyzed for certain parameters. Previously, dry weather investigations were only required at the outfalls, and analysis of samples was recommended but not required.

    9. Wet weather sampling must be conducted at outfalls in catchment areas with certain characteristics or system vulnerability factors (SVFs). No wet weather sampling was previously required.

    10. Based on the impaired waters within the municipality, some communities may be required to prepare phosphorus control programs (PCPs), or nitrogen identification programs or bacterial strategies. These were not required in the prior permit.

    The effective date of the permit is July 1, 2017 and you will have 90 days after that to file a notice of intent (NOI). If you have questions about any of these differences, or would like assistance from CEI, we can help you to minimize the cost of compliance and identify funding sources as well as resources for assistance. Contact me at (508)-261-5160 ext. 301 or epannetier@ceiengineers.com. If you want to talk to the real experts, call Rebecca Balke (rbalke@ceiengineers.com)  or Nick Cristofori (ncristofori@ceiengineers.com) at extensions 308 and 303 respectively. We’re here to help!

    Note that these are just the major changes and that there are many other more minor issues to address. Copyright 2016 Comprehensive Environmental Inc. all rights reserved

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  • The Use of LRA's to Avoid MCP Notification

    March 18th, 2015 by Rick Cote, P.E., LSP


    I introduced Limited Removal Actions (LRAs) as a potential option for avoiding notification in my “Reporting Releases under the MCP – 120-Day Notification” post. LRAs are allowed under certain circumstances where the release meets the 120-day notification criteria, and the total volume of soils for removal and treatment/disposal is less than:

    • 100 cubic yards of soil contaminated solely by a release of oil or waste oil; and

    • 20 cubic yards of soil contaminated by a release of hazardous material or a mixture of oil or waste oil and hazardous material.

    If these criteria are met then a LRA can be accomplished without oversight or reporting. However, it must be completed within 120 days of the discovery of the release and certain records must be kept.

    A LRA may NOT be used if:

    • The release or threat of release requires 2 or 72 hour notification; or

    • MassDEP has already been notified.

    A few more intricacies of an LRA – if greater volumes of contaminated soil are encountered during the LRA, MassDEP must be notified within the 120-day time frame and remedial actions must cease or approval sought to continue the removal actions as a Release Abatement Measure (RAM). Finally, records of the LRA must be kept for a minimum of 5-years and must include post-action oil and/or hazardous material concentrations and the volume and chemical characterization of excavated soils.

    For more information about CEI’s spill assessment and hazardous waste remediation services please contact Rick Cote, P.E., LSP directly at 800.725.2550x302 or rcote@ceiengineers.com or Rebecca Balke, P.E. at rbalke@ceiengineers.com.  

    Visit us at www.ceiengineers.com

  • Is Your SPCC Plan In Place for an Emergency?

    August 12th, 2014 by Eileen Pannetier


    Do you have a Spill Prevention, Control and Countermeasures (SPCC) Plan? If so, is it up to date with the best available information? If not, you could be subject to penalties and fines. The U.S. Environmental Protection Agency (US EPA) recently fined several facilities in New England anywhere from $3,000 to $10,000 for failing to have an adequate SPCC Plan in place. In some cases, these fines can exceed the cost to prepare the SPCC Plan itself, not to mention the headaches, legal fees and negative publicity.

    You are required to have an SPCC Plan if your facility stores either more than 1,320 gallons of oil in aboveground containers or more than 42,000 gallons in underground tanks and could potentially discharge oil into waters of the United States. Municipal facilities that are typically subject to these requirements include highway garages, transfer stations and recycling centers, where fueling, maintenance and/or waste oil collection are commonly performed. Plans generally outline where oil is stored, spill prevention practices, and response measures to implement in the event of a release. 

    A successful plan should be written so that information is easy to locate when needed the most - during an emergency. Unfortunately, that isn’t always the case and important emergency information often gets buried with the administrative requirements of the plan.

    CEI specializes in creating plans that are comprehensive but functional. Components may include a stand-alone “Action Plan”, focusing on facility inspections and spill response for use by workers in the facility and development of “Emergency Response Cards” or posters designed to hang on the wall near each oil storage location. Cards provide the most pertinent information for each storage area, including what is stored there, emergency response procedures and contacts, inspection and maintenance requirements, and a detailed map of the area showing the locations of oil containers and spill response equipment. These provide an invaluable quick reference in the event of an emergency, avoiding the need to locate and read through a lengthy written plan.

    For more information or examples of any of the materials referenced above, please contact Nick Cristofori, P.E. at 800.725.2550 x303, ncristofori@ceiengineers.com, or Rebecca Balke, P.E. at x308, rbalke@ceiengineers.com or visit www.ceiengineers.com for information on other services we offer.

  • Staying Ahead of Stormwater Phase II

    April 16th, 2014 by Eileen Pannetier


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  • Arsenic In Drinking Water

    April 7th, 2014 by Eileen Pannetier


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  • ASTM Phase I vs. MCP Phase I

    March 28th, 2014 by Stephanie Hanson


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  • Happy Spring!

    March 21st, 2014 by Eileen Pannetier


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